Earlier this week I was talking to the TTB offices in Cincinnati. I regularly reach out to them by phone to follow up on applications I’ve submitted for clients, which was the reason for my call.
As part of my conversation with the helpful woman who answered we mentioned that their staff numbers were reduced greatly last year. When I asked if that meant they’d be hiring more additional staff this year she stated, “well not now that the hiring freeze has gone into effect”.
OK- so I’ve backed off from the news as of late which meant I hadn’t heard about this.
Anyway- what does this mean to those of us in the winery world?
Slower turnaround times for your applications.
What might those applications include?
- New applications to start a new winery (OR alternating proprietorship!)
- updates to your existing winery application such as:
- new trade names – which will directly affect your label approval timelines
- change in location to a new winery site- this especially for all you alternating proprietors out there!
- request to cancel a TTB wine bond
- Change of ownership, when a winery is sold to a new business
So my word to the wise with this update? Plain and simple, plan ahead & then know how to follow up!
And be persistent in your follow up to the TTB offices for any application updates filed by your winery.
Along those lines here’s a link to my blog post I wrote last year about best practices for contacting the TTB offices
I have seen that they are approving COLAS without confirming that a trade name is on the basic permit. The TTB is putting the responsibility on the bottling winery to make sure the trade name is on their basic permit before they use the label.
I haven’t seen that yet in my filings Natalie. Their regs specifically state that any labeling trade names must be “approved by the NRC”.
https://www.ttbonline.gov/colasonlinedocs/ExtNetHelp/default.htm#!WordDocuments/gloss_dbatradename.htm So for a label approval to be issued before a trade name addition has been filed/processed by their NRC offices would be another example of inconsistency on their end in my mind, and thus frustrating for those of us who interact w/their offices on a regular basis.
Thanks Ann…that’s what we’ve heard too. Not only do we deal daily with inconsistencies on a routine basis but for the past couple of years we’ve faced extreme delays with application processing of all types…new, amended, updates, trade name additions, etc. A hiring freeze definitely won’t relieve this situation!
Thanks Linda- yes you totally get it! My hopes are that progress will be made starting this year to address these inconsistency issues w/their NRC and ALFD offices. The end result being in part that all application and review processes become much more predictable and therefore flow much smoother for both their specialists and all of us on the submitting end! I would like to see a reach out from us winery compliance experts to address these common issues we all face in dealing w/the TTB offices as a start to resolve it.